Range International: Securities Trading Policy



Liability limited by an approved scheme under professional standards legislation.

ACN International Limited Range 611 998 200

Adopted March 31, 2022



Range International Limited (ACN 611 998 200) (Company) and its subsidiaries (Group) is committed to complying with insider trading laws and establishing a best practices procedure for securities trading. This document describes the Company’s policy on dealings by Directors and employees in Company securities (Company titles) and securities of other entities.

The purpose of this policy is to:

ensure that all directors, employees and contractors of the Company (and their associates) are aware of insider trading laws as they apply to transactions in Company securities; and

protect the reputation of the Company and its directors and officers by seeking to avoid the possibility that misconceptions, misunderstandings or suspicions may arise as a result of transactions by directors and other persons who may be or to be perceived as being in possession of privileged information. This Policy seeks to do so by imposing additional restrictions on trading in securities by Restricted Persons (defined below).


Unless otherwise stated, this policy applies to:

all Group Directors;

all Group employees, whether full-time, part-time or casual; and all subcontractors and consultants working for the Group,

(each, Staff).


For the purposes of this policy, “securities” means shares, debentures, options to purchase new shares and options on existing shares, warrant contracts and other equity derivatives.




In summary, if you have inside information (defined in section4.2below) about the Company (or another relevant entity, such as a company with which the Company is considering a transaction) that is not publicly known, it is a criminal offense for you to:

deal in securities of the company (or securities of the other relevant entity);

advising or inducing another person to trade in securities of the company (or securities of the other relevant entity); Where

pass inside information to someone else (including co-workers, family or friends) knowing (or when you reasonably should have known) that the other person will or is likely to use that information to trade or induce someone else to trade , Securities of the Company (or securities of the other relevant entity).

This offense, called “insider trading”, may subject you to criminal liability, including severe fines and/or imprisonment and civil liability, which may include prosecution by another part of the Company for any loss suffered as a result of illegal trading.

  • 4.2 Inside Information

    “Inside information” is information that:

    is generally not available; and

    if he were generally available, a reasonable person would expect him to or would be likely to influence investors in their decision to buy or sell particular securities.

    The financial impact of the information is important, but the strategic and other implications can be just as important in determining whether a piece of information is inside information. The definition of information is broad enough to include rumours, assumptions, intentions of a person (including the Company) and information that is not specific enough to warrant public disclosure.

    It is important to note that you do not have to be an “insider” to learn inside information. That is, no matter how you learn the inside information (for example, you might learn it in the course of your job or by walking down the hall or in an elevator or while a dinner).

  • 4.3 Examples of insider trading

    The following list is illustrative only. Inside information could include:

the Company’s financial performance against its budget; any acquisition or sale of any assets by the Company; a possible change in the capital structure of the Company;

sensitive market information such as a material improvement or deterioration in expected earnings; a significant business update;

a proposed dividend;

senior management changes;

development of a new business line or a new product offer; Where

any potential claim against the Company or any other unforeseen liability.

  • 4.4 Insider trading is prohibited at all times

    If you possess inside information, you must not buy or sell securities of the company, advise or encourage others to do so, or transmit the inside information to others. This prohibition applies regardless of how you learn the information.

    The prohibition of insider trading does not apply only to information concerning the Securities of the Company. If a person has inside information about securities of another company, that person must not trade in those securities.


    In connection with the foregoing, directors, employees and contractors also have a duty of confidentiality to the Company. You must not reveal any confidential information concerning the Company, use such information in a way that could harm or cause loss to the Company, or use such confidential information to gain advantage for yourself.


  • 6.1 Additional Restrictions

    Additional restrictions (described below) on trading in the Company’s securities apply to Restricted Persons (described below).

  • 6.2 Restricted Persons

    For the purposes of this policy, Restricted persons are:

    all directors, including the CEO;

    all other key management personnel of the Company; and

    employees who have been notified that they are restricted persons for the purposes of this policy.

  • 6.3 Immediate Family Members and Entities Closely Associated with Prohibited Persons

    For this policy:

an immediate family member of a Restricted Person means a spouse or common-law, any minor child or child living with the Restricted Person (including the spouse’s or common-law children of the Restricted Person); and

an entity closely related to a restricted person means any family business or family trust that the restricted person or their close family members may control or have an interest in,

(together Persons closely related).

Each Restricted Person must:

ensure that any transactions by their Closely Associated Persons are carried out in accordance with this policy; and

make sure their Close Persons are aware of this policy and the restrictions it contains.

  • 6.4 Reasons for additional restrictions

    Restricted Persons are in positions where it can be assumed that they may come into possession of inside information and therefore any dealings by Restricted Persons (or their Closely Associated Persons) may embarrass them or have a poor image them or the company (even if a Restricted Person has no actual inside information at the time).

    This policy is designed to avoid the possibility that misconceptions, misunderstandings or suspicions may arise and also to protect the reputation of the Company and restricted persons.

  • 6.5 Trading Restrictions

    Restricted Persons must not trade in securities of the Company:

    without prior approval (see section Error! Reference source not found.); and during one of the following blackout periods:

    the period each year from the close of trading at the end of the full financial year until 10:00 a.m. on the trading day following the date of announcement on the ASX of the preliminary closing statement or full annual results;

    the period running each year from the close of the closing of the financial year until 10:00 a.m. on the trading day following the date of the announcement of the half-yearly results; the period each year from the closing of the markets at the end of each quarter until 10:00 a.m. on the trading day following the date of announcement of the quarterly results;

    within 24 hours of posting market sensitive information under ASX Listing Rule 3.1; and

    such other period as the Company specifies from time to time,

    (each one Blackout period).

  • 6.6 No short-term speculative trading

    Restricted Persons should not trade in the Company’s securities for short-term or speculative purposes. The Company considers “short term” to be a period of 6 months or less.

  • 6.7 Short selling, hedging and margin lending transactions

A Restricted Person must not engage in short selling of the Securities of the Company.

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